Before me, the undersigned authority, on this day personally appeared
Hollida Wakefield, known to me to be the person whose name is subscribed
to the following instrument, and having been duly sworn, upon her oath,
deposes and states as follows:

I. I have prepared this affidavit at the request of _______________

II. (Updated biographical material to demonstrate expertise and support
opinions is added. Current research also added when relevant.)

IV. A major focus of my professional activities is the research on the suggestibility
of the child witness and how children must be interviewed to obtain accurate,
uncontaminated information. We are current on the literature on this topic
and have written papers and made professional presentations on it. Our book,
The Real World of Child Interrogations, deals with this. We have
presented workshops and seminars around the world on how to permit children
to produce the most reliable and legally relevant information they can.

V. Since 1987 there have been major changes in professional opinions concerning
the susceptibility of children to suggestive and leading interviews. In
1987 the testimony of young children was generally accepted as truthful
and the prevailing opinion was that young children could not be led or "coached"
to make statements about abuse that never happened. The belief was that,
although children might be led through suggestive interviews to make unimportant
errors concerning peripheral details, they could not be led to make statements
about important, central events.

VI. As researchers became involved in actual cases and reviewed videotapes
of actual interviews, they observed that the research supporting the above
claims did not begin to duplicate what often happens in the real world.
As a result, there has been new research in the past two or three years
that has changed the consensus of scientific opinion. It is now generally
accepted in the scientific community that persistent questioning can lead
children to give elaborate accounts of events that never occurred, even
when they first denied them. Sometimes the questioning results in the child
developing a subjectively real memory for an event that never happened.

VII. S. Ceci and M. Bruck, who have conducted some of the most important
research, published an article in the Psychological Bulletin that
summarizes the current state of knowledge (The suggestibility of the child
witness: A historical review and synthesis. Psychological Bulletin, 113(3),
403-439, 1993). In this article, the authors draw several conclusions that
they state would meet the traditional Frye standard:

· Even young children are capable of recalling much that is forensically
relevant.

· There are significant age differences in suggestibility, with preschool-age
children being more vulnerable to suggestion than either school-aged children
or adults.

· Children can be led to make false or inaccurate reports about very
crucial, personally experienced events.

· Contrary to the claims of some, children sometimes lie when the motivational
structure is tilted towards lying.

VIII. These conclusions were not generally accepted by the scientific community
in 1987.

IX. The research described by Ceci and Bruck and the conclusions drawn concerning
child witnesses that is described in paragraphs VI and VII also meets the
requirements specified in Daubert vs. Merrell Dow.